February 4, 2002
Colorado Wildlife Commission
c/o Human Dimensions unit
Colorado Division of Wildlife
6060 Broadway
Denver,CO 80216
Re: Comments on Big Thompson Deer Herd Management Plan
Dear Commission Members:
On behalf of the 200,000 members and supporters of The Fund for Animals (The Fund) nationwide, including our members who reside and recreate in the state of Colorado, please accept the following comments on the Big Thompson Deer Herd Management Plan (BT Plan). Also, many of these comments are applicable to other Data Analysis Unit Plans under development.
Recently we were contacted by a number of Coloradoans who expressed serious concern about the proposal to revise the approach for managing deer herds in the chronic wasting disease (CWD) endemic area in Colorado. After review of the BT Plan specifically, we share their concern and must register our strong objection to the proposal to dramatically and randomly reduce the number of deer in the endemic area through liberal hunting seasons, and in all likelihood, intensive agency culling. Based upon the dearth of scientific information about the etiology, history, transmission, epidemiology, and diagnosis of chronic wasting disease, there is no biological, ecological or ethical justification for the Colorado Division of Wildlife’s (CDOW) proposal, particularly given the results of monitoring and testing over the past five years. Those results have confirmed that CWD in free-ranging wildlife in Colorado remains confined to a small area in the northeastern part of the state and that the level of infection has not changed appreciably, remaining on the average at about five percent. In addition, the CDOW’s proposed BT Plan is premature since research critical to proper deer management is ongoing.
Even the estimated five percent prevalence rate may be high considering that CDOW officials arrived at the figure based primarily upon the test results from the heads of killed deer submitted by hunters who voluntarily participated in the testing program and deer culled by agency. Given that testing animals entails a financial expenditure on the part of hunters, it may well be the case that the majority or a substantial percentage of hunters who participated in the program were those who may have suspected that the deer killed were diseased. Moreover, agency personnel often target animals with clinical signs of the disease. Such biases would necessarily skew any conclusions that can be drawn from such tests, potentially creating an artificial inflation of the level of prevalence because of the test sample. Furthermore, agency officials admit that monitoring of game management units varies between years and locations. The myriad of unanswered questions and the means by which the sample animals were selected indicate that the monitoring was not scientifically conducted, and thus one cannot extrapolate said sample results to the population with any precision or confidence. In other words, the prevalence level publicized by the agency heretofore is unreliable.
To make matters worse, the
CWD policy adopted by the Colorado Wildlife Commission (CWC) on September
13, 2001 reinforces this inherent flaw by stating that while public hunting
will remain the preferred and primary method of deer and elk population
control (the principal strategy of all the DAU plans), the CDOW, at least
for now, will not be responsible for testing animals killed by recreational
hunters. If the CDOW wants to arrive at a more reliable prevalence level,
then it makes sense to require all animals killed in the endemic area
to be tested. Even the quarantine just proposed by state officials will
not require testing of animals unless the carcasses are removed from the
endemic areas. For hunters who live in the area and whose deer carcasses
will remain in the area, there is still no mandatory testing.
CWD was first recognized in free-ranging elk in 1981, in free-ranging
mule deer in 1985 and in white-tailed deer in 1990 in both Colorado and
Wyoming. However, according to Elizabeth Williams with the Department
of Veterinary Sciences at the University of Wyoming, surveillance data
and epidemic modeling suggest CWD may have been present in free-ranging
deer populations for two decades or more before it was detected. This
means that the disease may have been present for nearly 40 years (perhaps
even longer) in free-ranging mule deer, and despite this length of time,
relatively few animals have been infected and the disease has not spread
outside of the endemic area. According to a recent release on the CDOW
website, since the initiation of monitoring in 1981, fewer than 500 animals
have tested positive for CWD in the entire endemic area.
Furthermore, since there is no information about the origins of the disease in wildlife, it is possible that the disease is naturally occurring in wildlife and should be allowed to run its course. Disease is a natural limiting factor in wildlife populations. Thus, until and unless the CDOW can prove that CWD is an introduced, non-native pathogen, it must consider allowing the disease to regulate wildlife populations. Of course, we recognize that the CDOW is not likely to contemplate such an approach because of its economic reliance on sustaining a large number of wildlife targets for license-buying hunters and the political pressure being placed on the agency by commercial agricultural interests from both the livestock and “alternative” livestock industry, the latter of which creates the very artificial conditions that tend to increase transmission risks.
Only recently have scientists turned their attention to studying transmissible spongiform encephalopathies (TSEs) or prion diseases of which CWD is a member. Neither the causative agent nor the mode of transmission is known definitively, and as has been the case with so many scientific theories over the years, what may at first seem a reasonable hypothesis may subsequently turn out to be erroneous. Preliminary studies indicate that abnormal proteinaceous agents called prions apparently cause the disease. The infectious agent is probably transmitted laterally through animal-to-animal contact and/or ingestion of food and/or water contaminated with the saliva, urine and/or feces of an infectious animal. Although researchers currently believe that maternal transmission is unlikely, it may also occur. The level of an infectious dose is not known, nor is it known when an infected animal becomes infectious. The minimum incubation period is unknown as is the clinical course of the disease. Whether particular genotypes may be more susceptible or resistant to the CWD agent is also unknown. Furthermore, given the extremely persistent nature of the CWD infectious agent, environmental contamination may play a significant role in transmission. In other words, killing animals will not necessarily eradicate the disease nor reduce its prevalence. Indeed, even the CDOW concedes that “At this time a negative correlation between CWD prevalence and population numbers or density has not been demonstrated.” (BT Plan, p. 13) Thus, the CDOW’s proposal to engage in random culling, indiscriminately removing both healthy and diseased animals, may give the impression that the agency is addressing disease concerns, but in reality, there is no scientific basis for such an approach. A considerably better understanding of prion diseases is needed before wildlife agencies adopt drastic measures that may ultimately prove counterproductive to controlling the spread of CWD and to reducing its prevalence.
According to the BT Plan, a large portion of Data Analysis Unit D-10 (D-10), Game Management Unit 20 (GMU 20) is located in Rocky Mountain National Park (22%) and some of the highest deer densities on winter range occur on Boulder County Parks and Open Space (BCPOS) lands (3%). In addition, 49% of D-10 is private land, much of it surrounding the town of Estes Park. (BT Plan, pp. 3, 8) While the BT Plan acknowledges the difference in management missions of the CDOW, the National Park Service (NPS) and local parks and open space departments and that the lethal removal of deer from park lands and city environs may generate contentious debate, there is no discussion of the potentially adverse impacts that increased hunting pressure or culling operations may have on deer behavior, movement patterns and distribution. A good example of how hunting can change wildlife movement patterns and distribution is to examine the behavior of elk in Grand Teton National Park who have learned to effectively evade hunters’ guns as they make their way to the National Elk Refuge each winter. It is reasonable to speculate that deer who are unnaturally stressed by killing operations will also seek sanctuary in areas where they can escape such pressure. Such behavior may artificially increase deer density in certain areas within D-10, and consequently, foil the CDOW’s stated purpose of decreasing density. Currently, the NPS may allow the removal of visibly infected deer, but The Fund for Animals can assure the CWC that any efforts to expand culling operations on national and state park lands to allow for indiscriminate killing of wildlife will be met with public outcry and with legal intervention.
Non-lethal efforts to reduce deer density in certain areas of D-10 where the infection rate is higher should be explored. For example, the BT Plan does not provide a description of outreach efforts to educate people about the risks and consequences associated with artificial feeding of deer in the Estes Park area and other residential areas, which, according to the BT Plan, has an inflated infection rate. Although the specific cause for higher incidence of the disease in the area is unknown, the CDOW speculates that it may be attributable to higher densities of deer attracted to ornamental vegetation, homeowner feeding stations and protection from predators. (BT Plan, p. 9) While the BT Plan discusses efforts to discourage illegal feeding, there is no discussion of the extent and outcome of law enforcement investigations and whether the penalties for violations are sufficient to serve as an effective deterrent. What types of outreach efforts has the CDOW engaged in to educate area residents of the problems associated with feeding? To what extent are aversive conditioning methodologies such as repellents, fences and scare devices being used by property owners and/or residents? Does the CDOW provide any technical and/or financial assistance to individuals who request it? Does the CDOW provide lists of plant species that are unpalatable to deer to property owners/residents? For reference, I have attached to this comment letter a Fund publication that includes such a list along with suggestions for other aversive conditioning alternatives.
Furthermore, the CDOW has, not surprisingly, downplayed the potential usefulness of immunocontraception as a non-lethal management strategy to reduce deer recruitment and ultimately, density. Such a methodology might provide a humane means to allow researchers to assess whether there is a correlation between fewer deer, reduced density and disease prevalence. Unfortunately many wildlife officials are unwilling to objectively analyze this technology because they are either unfamiliar with its many useful applications or have a vested interest in selling hunting licenses as a source of revenue for their operating budgets. The technology has been used quite successfully in several deer and wild horse herds in the country and The Fund urges the CDOW to consult with experts in the field of immunocontraception research and application to determine whether the technology is a viable management option, particularly in areas such as city environs. An integrated management approach incorporating fertility control to reduce recruitment and aversive conditioning to aid in the dispersal of deer from areas of high concentration must be comprehensively analyzed.
The BT Plan fails to describe current predator management strategies within and outside the endemic areas. What are the population estimates, age structure, sex ratio and reproductive potential for mountain lions in the area? What are the current hunting quotas for mountain lions and how might the hunting seasons be changed to enhance the role of predators in helping to stabilize or reduce deer populations in the area? What are the population estimates for coyotes in the area? Are governmental agencies and/or private individuals conducting any predator control activities in the area? Has the CDOW analyzed how removal of large numbers of deer may impact predator numbers and predator/prey dynamics? The BT Plan fails to provide this critical analysis. The proposed removals of significant numbers of deer from the endemic area may result in serious, adverse biological impacts to predators, particularly mountain lions who rely on deer as important prey. In fact, the CDOW may be setting the stage for increased incidence of predator/human conflicts. The removal of deer may also encourage livestock depredation. Moreover, given the probability that deer will seek refuge in areas where hunting pressure and culling operations are light or nonexistent, it is also likely that mountain lions will follow their prey into these same locations. It is unlikely that lion presence will be well received in city environs and CDOW officials will be left with the unenviable task of trying to explain to the public how its management actions may be responsible for such scenarios.
If the CDOW is serious about decreasing deer density in the endemic area, the agency must re-evaluate the proposal for sex ratios in D-10 and other DAUs. The proposal for 10-35 bucks:100 does is unquestionably designed to pacify hunters’ desire for an adequate supply of “quality” bucks. While the CDOW claims that having a higher ratio of bucks to does would foster emigration and buck movement, the agency provides no scientific data to support this claim. A more natural ratio of bucks to does, e.g., 50:50, could significantly minimize and even reduce herd growth. According to the CWC policy for CWD, conflicts between disease management and recreational hunting opportunity shall be resolved in favor of disease management. The CDOW must decide if the priority is indeed disease management as stated by the current CWD policy or if pacifying the hunting constituency is more important; the agency can’t have its cake and eat it too. Targeting for a more natural sex ratio is a responsible management strategy and demonstrates that the agency embraces an ecosystem-management approach that puts the welfare of wildlife and ecosystems first, while at the same time helps to naturally achieve one of the objectives of the BT Plan to reduce deer populations. Based on past management decisions, the sex ratio has been skewed to favor enhanced reproductivity, and consequently, the population is artificially inflated.
The BT Plan states on page 12 that: “Hunting is often considered an ‘unnatural’ deer mortality factor. In reality, predation on deer by humans has occurred in North America for thousands of years and it can be argued that its absence is unnatural.” (Emphasis added) Unfortunately, the BT Plan fails to describe the actual character of hunting and wildlife management today -- a strategy that is frequently designed to create the very overabundance of animals that hunting allegedly controls. Nothing could be a better example than the aforementioned discussion of sex ratios in which wildlife agency officials debate whether they should focus on “quality vs. quantity” management. In reality, wildlife management today is essentially a commercial operation where animals are treated more like agricultural crops than as integral components of complex ecosystems. Managing wildlife in a framework that is rooted in concepts such as “maximum sustained yield” and “harvestable surplus” underscores the grim reality that despite claims to the contrary, there is nothing “natural” about the recreational killing of wildlife. Unleashing regiments of hunters into the fields and woods for a relatively short period of time to terrorize, cripple and kill countless fit and unfit animals unquestionably alters the behavior of wildlife and adversely impacts ecosystems. These undesirable impacts will only be intensified by the proposal to indiscriminately and aggressively cull even more animals. It also emphasizes the difference in old school and new school thinking about what constitutes responsible wildlife management. Even the BT Plan states: “With increasingly intense hunting pressure, deer may move in greater proportions to private or unhuntable parks and open space causing limited hunter and CDOW access to become an issue.” (BT Plan, p. 3) This further demonstrates the irrationality of this approach, particularly considering that the CDOW is proposing to forge ahead with the BT Plan before the results of ongoing research are known.
Moreover, the BT Plan does not adequately address how the removal of large numbers of deer may actually trigger reproduction in the remaining animals despite conceding that “Herd reductions may result in a density-dependent population response leading to an increasing fawn:doe ratios.” (BT Plan, p.15) Compensatory natality is commonplace in ungulates under this type of scenario. An increase in juvenile deer may also potentially result in unpredictable movement patterns due to less fidelity to a certain area and increased disturbance by hunting and culling operations.
The CDOW states that culling will also be used as a tool to remove deer exhibiting undesirable movement patterns between endemic and non-endemic areas (BT Plan, p. 3). However, agency officials appear once again to discount another distinct possibility. Aggressive culling operations, including aerial gunning operations, may force deer outside the endemic areas and/or onto lands where management options are minimal. According to the BT Plan, the incidence of CWD in the southern 25% of D-10 is sporadic with only one case detected south of the St. Vrain River. Until the ongoing studies to learn more about deer summer and winter movements (especially immigration into and emigration from the endemic area) in both D-10 and D-4 are completed, it makes no sense to introduce another variable that may significantly impact natural movement patterns. (BT Plan, p. 3) This is especially important when considering management proposals for Sugarloaf Mountain in Boulder County. It is our understanding that the test results from both hunter and road killed deer from this area indicate that the deer population in the Sugarloaf area is already at the prescribed prevalence level of CWD policy, i.e., <2% in any GMU.
The CDOW also proposes to engage in selective culling operations in areas where deer exhibit seasonal movements to and from areas of high CWD prevalence in order to prevent CWD from spreading and to remove a high proportion of CWD positive animals. (BT Plan, p. 2) However, while the CDOW offers some statistical data, albeit unreliable, re: CWD prevalence levels within the endemic area, there is no discussion of the rate of spread. Furthermore, although the CDOW is engaged in a study in GMU9 that is examining the relationship between CWD prevalence and population size, it failed to provide any preliminary data from this study in the BT Plan. If the data suggest that large-scale reduction in deer populations (approximately 50% in GMU-9) is not affecting CWD prevalence, then the entire BT Plan is unjustified.
Without these baseline data, it is impossible for agency officials and the public to ascertain whether management strategies are working to prevent the spread or not. According to a January 16, 2001 press release, tests had confirmed that the disease had not spread. Has this conclusion now changed? It appears that maintaining the status quo while continuing to conduct monitoring and research may be the best preventative measure. Rocking the boat with so many unknowns is exceedingly precarious at best. At a minimum, the CDOW should wait to implement any reduction until the ongoing research in GMU 9 in D-4 is completed. (BT Plan, p.16)
The BT Plan does not discuss how the CDOW intends to identify CWD positive animals. Given that agency officials admit that most animals who appear ill are probably suffering from other diseases, such as hemorrhagic disease, or arthritis, nutritional deficiencies, dental attrition, bacterial or viral infections, old age or injuries, they cannot necessarily rely upon appearances alone to guide their selection. Furthermore, clinical signs of CWD are not specific and the clinical course of the disease may range from a few days to a year. Will the CDOW utilize the new live tonsil biopsy and urine tests that are now available to positively identify which animals are infected? Where will the tests be used and to what extent? Nothing in the BT Plan discusses the use of these tests. In fact, the BT Plan erroneously states that live animal tests are unavailable. (BT Plan, p.17) This error must be corrected and a comprehensive analysis of how live animal tests will be used in CWD management efforts must be immediately prepared.
The CWD policy allows for the use of helicopters and fixed wing aircraft for culling operations. The BT Plan entirely fails to analyze the impacts of aerial gunning operations on both deer and other species within the endemic areas. Undoubtedly, gunning operations with the use of helicopters and fixed wing aircraft will disturb and stress countless wildlife species in D-10. The BT Plan offers no discussion of the species of wildlife impacted, the numbers of animals impacted, the distance and size of the areas where aerial gunning may occur, nor the conditions of those animals which will differ from season to season based upon a number of variables spring and summer forage production, weather patterns, age, sex, weight, condition and reproductive status of animals, etc. The CDOW has apparently dismissed the extreme cruelty of aerial gunning operations that not only terrorize and result in the wounding of target species, but also have a multitude of adverse impacts on non-target species. If aerial gunning is to be used on federal lands, including Congressionally designated wilderness areas, compliance with the National Environmental Policy Act will be required
Nor does the BT Plan discuss the potential safety threats to personnel and/or the general public. For example, since 1989, the United States Department of Agriculture’s Wildlife Services, an agency routinely engaged in aerial gunning, has crashed 18 helicopters or airplanes, resulting in the deaths of seven individuals and injuring 21 more. Will Colorado taxpayers be expected to underwrite the costs of investigations and workers’ compensation in the event of any accidental crashes? Are recreationalists and other public land users as well as property owners expected to know when and where aerial gunning operations will take place? How does the CDOW intend to ensure that the unsuspecting public is not placed in jeopardy?
Finally, for these and other reasons, the Fund urges the CWC to reject the approach outlined in the BT Plan and to require the CDOW to prepare a comprehensive analysis of the aforementioned issues, to complete and provide the results of ongoing research, to engage in scientifically and ethically sound studies in an effort to answer the multitude of questions about CWD and to implement non-lethal alternatives for minimizing disease transmission. Thank you for your consideration of these comments. Please keep us apprised of any developments on this and other issues related to CWD management in Colorado.
Sincerely,
Andrea Lococo
Rocky Mountain Coordinator
Andrea Lococo
Rocky Mountain Coordinator
The Fund for Animals
P.O. Box 11294
Jackson, WY 83002
Telephone:(307)859-8840
Fax:(307)859-8846
<www.fund.org>
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